Poland’s thin cap rules are becoming less generous: the limitation on deductible interest looks likely to be based on a much lower gearing ratio; and the definition of a connected loan becomes stricter. India’s preoccupation with marketing intangibles looks set to continue: the extent to which marketing costs incurred locally, for promoting the business in India, constitute an international service, rather than purely supporting the local business, is in contention once again.
Poland’s thin cap rules are becoming less generous: the limitation on deductible interest looks likely to be based on a much lower gearing ratio; and the definition of a connected loan becomes stricter. India’s preoccupation with marketing intangibles looks set to continue: the extent to which marketing costs incurred locally, for promoting the business in India, constitute an international service, rather than purely supporting the local business, is in contention once again.